Securing tomorrow - Navigating the Biosecure Act and strategies for compliance and resilience

Sharmela Kalmer: Hello to our audience and welcome to our webinar "Securing tomorrow - Navigating the Biosecure Act and strategies for compliance and resilience". My name is Sharmela Kalmer and I'm an IP partner at Gowling specialising in life sciences transaction work.

So, let's dive into our topic today: The Biosecure Act once passed will mark a pivotal shift in the US Biotechnology Policy. This legislation has been introduced by the US Government to address growing national security concerns. So, what is its impact and how best to prepare.

To answer this and other questions I am happy to welcome today Bernardine Adkins and Evan Chuck that will help me unravel the uncertainties and certainties and explore strategies to navigate the regulatory landscape.

Let me start by introducing you to my fellow partner, Bernardine Adkins, who is a veteran EU trade and competition expert with over 35 years' experience providing strategic advice to businesses and governments alike. She is qualified both as a UK solicitor and a Belgium advocate and is a member of the advisory board of the Competition Law Forum at the British Institute of International Comparative Law and the Competition Policy Committee at the American Chamber of Commerce to the European Union.

My other special guest is Evan Chuck who is a partner at Crowell. He regularly advises corporate leaders and board of directors helping them navigate through the increasing, challenging regulatory landscape around the globe, particularly in Asia and in the context of duelling US and China laws and regulations resulting from geo-political competition.

Evan has more than 30 years of cross border corporate and regulatory experience and spent a decade working in Shanghai. In the past year he has worked on some of the most noteworthy matters involving the US-China conflict involving Xinjiang forced labour and Chinese circumvention of the US trade laws. He is also one of the few US lawyers who has represented a multinational company sanctioned by the Chinese Government. He helps leads Crowell's Asia practice.

So, let's set the scene first. The Biosecure Act is a new law which is being considered in the US Congress. It would stop US federal funding including loans and contracts from going to companies that use biotechnology, equipment or services from certain Chinese companies or from countries like North Korea, Iran, Cuba and Russia. This law could impact pharmaceutical and biotech companies that rely on US Government funding and contracts if they use equipment and services from these foreign providers. Last week the Act was voted through by the house committee and oversight and accountability. Evan, can you please briefly walk us through what this means and what the timeline for the implementation of the Act is?

Evan Chuck: Sure. Pleasure. Thank you. Well perhaps another issue in the United States US congress and global parties getting tough on China. This is just one of the latest tools the US Government is refining to spurn off national companies. This time in the life sciences sector to de-risk or de-cover from the Chinese life sciences sector. Two of key policy drivers in the US are 1) reducing reliance on China in our life sciences supply chain and 2) making sure that the health information of the US population does not end up in the hands of the Chinese congress party.

The republican sponsored this legislation. Representative Wenstrup called this the first step in a multi-faceted approach to protect national health security. What happened in Washington D.C. last week was that our House of Representatives introduced a new version of the Act and advanced it through a committee mark-up - as what we call it - so it is ready for consideration for the entire House of Representatives. Many parties from the industry provided inputs about concerns even of this revised language.

So, to answer your question here is what the Act aims to do 1) force US drug manufacturers to end their relationships with so called biotechnology companies of concern by 2032. This includes Chinese companies like VGI, MGI, Complete Genomics, Wuxi App, etc. and any subsidiary parent affiliate or successor of their entities and we respect any work that involves US Federal procurement. A key phrase to focus on is "involved in US Federal government procurement" because due to our US healthcare and research institutions, some estimates suggest that the Act could impact the healthcare of half of the US population. It also prohibits federal agencies from procuring or obtaining a biotechnology equipment or service "from a company of concern", which identified by the US Office of Management and Budget in coordination with a group of US agencies. If you are familiar with our US "CFIUS" - the Committee on Foreign Investment in the US - the Act seems to contemplate a similar inter-agency review process and designation process. The Act also prohibits agencies from entering into a contract or renewing contracts with any agency that uses biotechnology equipment, or services produced or provided by a biotechnology company of concern after the statute goes into effect.

So, in terms of the next steps and timeline for the Act. So this bill has gone through the review process called a "mark-up" in both the United States Senate and the House of Representatives. So the bill may now make its way to the floor to be voted on in either chamber. Whilst it is possible for the bill to be brought up for a vote on its own, it is more likely to be inserted into a larger piece of legislation. Bill proponents have mentioned the National Defense Authorization Act or NDAA as such a piece of legislation. A previous version of the bill was included in an early version of last year's NDAA before being removed. So far, the bill has attracted broad bipartisan support in the House and Senate. It was voted out of committee by a vote on 11 to 1 in the Senate and 40 to 1 in the House. The bill's strong support suggests that there is a good chance the bill could advance and become law this year. Concerns remain however that certain aspects of the bill are already brought and could have unintended consequences. So our sources suggest that the process could move as early as this Summer but more likely in the Fall.

Shamela: Yeah, that is quite fast moving. Bernardine, politically how do you think that the EU will react to this?

Bernardine Adkins: It is a bit of a cliché, its complicated because the EU has a far more ambivalent attitude towards China. So ultimately trade policy which is sort of trade policy but also public security, that faltered in the value of the EU and so it needs to be done in common the European Commission, which is the executive, the civil servants, these also have the accord of the member states. We have seen this ambivalence being played out before with the solar panels where China was allegedly dumping its solar panels in the EU so the European Commission was gung-ho about we need to start anti-dumping investigations against the Chinese whereas the member states were saying hold on, we need Chinese investment. We like Chinese money, we like foreign direct investment. We have seen this played out most recently for example with at the beginning of May with Xi Jinping's state visit to Europe, when he came to Europe, he came to France first of all. France has always ruled out a beautiful red carpet for the Chinese because it does like Chinese FDI. But Macron is becoming more pugilistic towards China because of the Ukraine and its support for Russia. And also, significantly von der Leyen, the president of the European Commission, she came out to visit also to visit China. So, there is a real ambivalence there. On the one hand they want this FDI and on the other hand they do see China as a systemic rival. But by the same token where did Jinping visit after that? He then went to Belgrade, to Serbia, which is an applicant to the EU with huge investment of China in Serbia. And then he went on to Hungary which is sort of very much on the naughty step viz a viz with the rest of the EU but again huge amounts of infrastructure investment by China in Hungary in terms of its Belton Road initiative, in terms of energy investment as well, looking at building a railway as between Budapest -Belgrade - Scotia - Athens to Piraeus the port which is operated by a state-owned Chinese company. Basically, a bridge head into the European market. So, they are not going to suddenly go over the top and say 'yeah absolutely we completely agree with the US here in terms of we must do something viz a viz China'. But they may slowly get there in the end. But it will probably take longer and perhaps be done with a little bit more subtly than we are currently seeing with the US.

Sharmela: OK so you are talking about the de-risking and talking about de-risking, Evan you mentioned the transition period. So what measures should be taken by the US and European companies who are working with Chinese companies which are listed by the Act or others who are not yet identified by the Act.

Evan: I think any biotechnology company that ultimately has a contract with the US Federal Government, so could be direct or indirect or otherwise who works with the clients on a US Federal Government contract, needs to structure their operations so they avoid entanglements with companies of concern going forward. So, companies that use products, these kinds of products, should consider the following: 1) closely examine its supply chain including development and research components and determine exposure to PRC companies particularly those which have already been designated in the Act. 2) They should conduct a detailed inventory of intellectual property involved in the supply chain and determine where the company may be over-reliant on Chinese technology. For example, if there is any Chinese company of concern own the new technology or any successful transition or require a licence of that technology from the Chinese company. Working on the difficult task to creating transition strategies, where you pay close attention particular to the agreements, that form the foundation of contractual relationships in the supply chains. Special attention should be given to termination fees, liquidated damages and royalty fees that might be triggered as a result of any transition strategy. They should also identify strategic business and legal issues but make transition difficult or impractical including seeking new regulatory approvals that may be needed as part of any transition plan. Those can be extremely time sensitive particularly in the US with our FDA. Determining the cost of transition strategies and obtaining consensus for corporate stakeholders is very important to provide for appropriate financing contingencies to cover these potentially significant increased costs. It is perhaps most importantly, given the sort of collate status of legislation, really now is the time, if you are not already monitoring and if you are interested in participating in the ongoing legislative process in the US to shape legislation and to advocate for changes, this is definitely the time to do that because the transition difficulties have clearly been identified by law makers as an area that needs further refining.

Bernardine: Yeah, absolutely concur with what Evan is saying and frankly if this wasn't happening, we are going to be forced to do it, they need to be doing it anyway for all sorts of other reasons. People absolutely need to know their supply chain, who their trading partners are and so a similar situation for different reasons is happening in the EU with the Corporate Sustainability Due Diligence Directive is coming through. Yes, it was watered down and it was the Germans and in fact 13 other member states said this is too much, asking companies to absolutely be aware and be alive and be responsible for where on its watch in respect to its direct and indirect clients where they may be involved in potential human rights abuses or environmental harms. But it is going through and yes it has been watered down but it is coming to a place near you so to speak. And we are seeing it also with respect to sanctions for example, because time was if we were ever engaged with sanctions were we used to say don't worry about EU sanctions. Whatever else matters make sure you obey US sanctions but now EU sanctions in the various member states they are very real and also post Brexit with respect to the UK sanctions they are very real and very real enforcements happens as a result. So people are going to have to become more sophisticated and know their supply chains in a way that perhaps they have never really had to know before and in the UK we certainly saw it with Brexit because there was the fear of a no deal Brexit. And we were quite stunned at the number of people who really didn't necessarily know, and they have been trading with people for a long period of time, lost sight of there the contract was, how it was so now the type of people to do their housekeeping if they haven't really done so and be on top of that governance. And also the other thing we are seeing in terms of compliance, which I think is so important, it is not just who we are trading with, but it is about training your people to be alive to people who are interested in circumvention. Because they may be some tricksters out there who are yes we see what is coming here, let's just hide what we are getting and from where. So people need to train their people and have appropriate processes in place to monitor, to double check, to be suspicious frankly as to who they are dealing with. Because it is a complex world now.

Sharmela: And talking of the complexity and how far reaching this is, this is what I want to move on to next. How far reaching is this Act and here I am really thinking about the end user. So initially when I looked at this Act and that it affects federal US purchasing agencies which probably is the closest the US gets to the NHS, so these US agencies are buying medicines for people like the veterans, circa nine million of them, Medicare recipients 65 million of them, federal employees eight million of them. There is MedicAid. There is Indigenous population, there are those who are incarcerated and so on and so forth and I just did a back of the envelope calculation and I realise that it actually affects practically half of the US population. So what I'd like to understand is, is this an issue just within the US or is it that so the companies will be making something the medicines differently for the people in the US or it actually affects everybody because it is not very efficient or practical to perhaps make medicines differently for lots of different sets of people and it would be great to get your input here.

Evan: Following up on what Bernardine said, the world is very complicated and particularly in this area, a lot of the potential impact of the Act can be far-reaching because of how independent the life sciences industries are frankly across cross borders and how it is intertwined with Chinese providers. Many life sciences companies rely on these biotechnology companies of concern to deliver a wide range of services and products, including research and development services, manufacturing of commercial products, including FDI approved medications for the US, clinical stage products for ongoing clinical trials. Industry groups have contended that they will face likely fulfilment difficulties that access to these companies of concern are reduced or eliminated not just in the US but on a global basis. Particularly if there is no substitutable provider of capacity with the technological and regulatory approvals on hand. Industries also contended that they also may experience difficulties in fulfilment if the biotechnology companies of concern also reduce capacity resulting from a loss of revenue that can be traced to US Government contracts. Examples would include difficulties in obtaining slots for manufacturing runs and medicinal products with the biotechnology companies concerned, which also caused disruption in supply chains or delivery of the products. Again not just US but potentially globally and this could result in obviously price increases in drug prices. I think strategically it would be likely the industry would need spend time and resources to find alternative venders that can produce the equivalent products. These costs will also be likely passed along to the consumer whether in the US or outside the US and also our US Government says that building resilient supply chains will actually not result in these costs. I have my doubts about that.

Sharmela: And then Bernardine do you think you know the EU would ever go down a similar road and if so, what sort of legislative tools do you think they have available?

Bernardine: In terms of the EU bear in mind the EU, contrary to what the Daily Express or Daily Mail would have us believe, it is not a superstate. It is great towards treaties and so ultimately so with public security it is out with the competence of the EU. So really if they were to do something directly very much in parallel with what the US is doing, this would be something that falls under political cooperation, so that would be a question of inter-governmental arrangement. What is fascinating in this whole area is to watch the EU creep and so we have in the air a foreign direct investment, the US has long had CFIUS and it is only recently that the EU is starting to create its own equivalent. So theoretically technically speaking this is without outside the value of the EU. What it's done it has produced a foreign direct investment regulation but what it does it simply cooperates; it gets the member states to talk to each other about what investments they are looking at. But also trying to initiate best practice. So suggest to people under the regulation, that you should deal with it in a certain timelines, obey the rule of law, etc., etc. So we are as I said in theory not within the EU competence but there is a creep there. As well as something perhaps equivalent to careful political cooperation, we also have the foreign subsidies regulation and this was recently adopted, it came into force about a year ago. The EU has always denied this, but I think it is more or less aimed at the situation where a third country, i.e. China, is in receipt of large subsidiaries and then as they say distorts competition of the single market. So, the idea really to have a level playing field as between EU companies which are subject to EU subsidiary regulation and third countries. But it is, I think a very limited tool in that it refers to a situation where it has got large thresholds, large amounts of money are given to a third country company but also it is about advantage, it is about bunch of money. It is not about the situation of, or information that percolates back to the Chinese military. At the moment in terms of what the EU has on the stocks, I think it is quite limited. So, we would have to see something unique and different, and I think it will be very much what the member states would do as opposed to the EU itself.

Sharmela: OK so what then do you think would be their immediate reaction with respect to the implementation of this Act?

Bernardine: Well, I think where we have seen before that the US did something and I look back it was 2018 it seems such a long time ago. At the time it was quite shocking, when Trump imposed the section 232 tariffs on steel again, largely aimed at Chinese, but it applied to the whole of the world. The Chinese then imposed safeguard measures because they said there is going to dislocation of trade with Chinese still which would have gone into the US, it is going to come to the EU. So they put safeguarding measures on and they also imposed accountable measures on the US, on US motorcycles and whiskey because they said it is also unfair to impose tariffs on the EU. I can't see that similar sort of trade spat going on here because this a question of public security. And yes we are seeing again more recently a nuance approach between Biden is imposing tariffs on green tech products, some would say he is actually taking quite a nuance approach if one compares to what tariff Trump did, and the EU has already said we are going to do these blanket tariffs. But as I said, this is not such a simple situation, this is about public security and what is really quite interesting is the EU haven't really said very much about this yet and it may be regarded as this is something the biotech can look after itself. It is a sophisticated market. It is a global market. It can self-regulate. So I think it remains to be seen how they will react and it may be a question of making political noises or maybe they will start to think about doing something themselves as we saw with Huawei. Initially the EU is pretty angry about Huawei but eventually it came round to being concerned about Huawei, 5G and the Internet of Things.

Sharmela: And Evan, just taking a step towards research institutions. What about US institution receiving federal funding, you know, what measures are in place so that we are not creating unnecessary barriers impact scientific collaboration between EU and the US?

Evan: That's a good question, it is one of the unanswered questions in the current draft legislation. There is talk of creating what we call them Safe Harbours, so a special sort of categories. But things have not been said in any way and we will need to see how things develop as the legislative process continues. The US industry has contended that again non-profit organisations, including universities and academic medical institutions that perform basic research in clinical trials, so sponsored by biotechnology and pharmaceutical companies, could be adversely impacted because they do work with some of these Chinese biotechnology companies of concern. Many of them receive US federal funding so if they cannot sufficiently de-risk, they may lose their federal funding and if they can't de-risk some of the relationships. If that happens the industry also could lose access to the expertise that these institutions provide because they also do some of the work for the pharma companies, so therefore can limit drug development programmes. This can materially impact them particularly where EU institutions are collaborating the US institutions like our National Institutions of Health.

There world's intertwined as Bernadine was saying. I would say just to add to what she said earlier, the US with respect of foreign direct investment last Fall announced for the very first time that we would be putting on the US side capital controls on outbound investment which historically can impact European investors. Now interestingly in that discussion biotech was actually one of the pillars including lots of computing, AI, semi-conductors but it was taking off at that time. And so it is interesting that we are seeing this US Biosecure Act taking its own line and maybe that reflects some of the complicated inter-relationships but we have our own FDI that's coming. Also, similar to the foreign subsidies comment that Bernardine made, just this past month in April our US Congress Department for the very first have been accepting arguments in the countervailing duty and anti-dumping space for something called trans-national subsidies. So analogous to what Bernardine said, this is where China has been giving subsidies largely in the form of their Belton Road initiative to third countries, countries like Vietnam, Malaysia and other places, and for the very first time, we have countervailing duty trade revenue cases filed against countries like Vietnam for things like solar cells where the allegations include these trans-national subsidies, subsidies from China to the Government of Vietnam or subsidies that China may be giving to Chinese companies as it pushes them to basically create capacity in overseas' markets. So it all I think we all have different tools but the US tools are certainly being build up by American policy whether the Biden administration or perspectively if President Trump gets a second term.

Sharmela: Bernardine did you have any thoughts on you know institution collaborating?

Bernardine: In terms of this impeding scientifical collaboration between the US and the EU, one thing one would hope is the legislation is an adequate transitional period for people to get their house in order and arrange their supply chains. But you can't help but feel there is also an inevitability of a 1994 situation arising where the world becomes these big three trading blocks, Oceania, Eurasia, and East Asia. So what way round is there? I think people are going to be very much EU. Yes, but they will have scientific collaboration within the rising programme and the US. But very much aboard organisation viz a viz China in this particular area.

Sharmela: Yeah, exactly. In terms of like you know other people, other groups that might be interested in this is investors and insurers you know. What the sort of considerations that they need to be thinking of when insuring or investing these kinds of companies.

Evan: I know we work with investors, global investors and insurance companies and then look at these decisions through various lenses including ESG. You know for investor perspective, like a private equity, the investee needs to be able to articulate clearly how the legislation will likely impact projected costs, particularly these transition and compliance costs, and how that will impact ultimately with internal investment. Investors should ask the investees the hard question. You know, what would be the worst-case scenarios that would likely present and how would the investee management deal with those scenarios and at what cost? Would the cost and risk out-weigh the upside of the investment. I was working with a client just a couple of days ago that part of the exercise involves essentially a very, very sort of, what we call in the weeds road map, decision sort of tracing throughout their entire supply chain and they have to undertake that to really understand how to even answer those questions. Separately on the lender side, I have also advised global financial institutions, also looking at insuring business that rely on China supply chain from the ESG perspective. Particularly for me it has been historically the S the social part, while we have not seen the issue of Xinjiang Forced Labour and in the China biotechnology supply chain being sort of highlighted. We have seen it present in the medical device manufacturing supply chain. What's more complicated these days is that there are reports and investigations based on China's movement of Xinjiang's Forced Labour around the country ostensibly to obscure compliance with laws like the US Enforced Labour Prevention Act and laws like the EU Forced Labour legislation internal equivalents. It is interesting followed by a comment from Bernardine, when we first about two years ago started talking about a UFLPA to some of our European friends, colleagues and clients, there was sort of almost sharp sceptical reaction, well that is just US how would it possibly impact us. Just this past several, past few months there were Porsches and Audis that were detained at US ports because they had a control component which was manufactured in Xinjiang. I think the auto sector will continue to have additional scrutiny. I just don't think they have gotten to the biotech pharma categories yet, but I do know that there are US customs, border patrol, CBP is getting a lot of federal funding because of the bipartisan support and so I would expect a combination of very sophisticated methods to detect forced labour. But it just goes to show it is one of multiple tools but they are all going to be acting in concert and goes to Bernardine's early appoint, clients need to know what their supply chair is for a variety of reasons and they need the sort of advanced time particularly with respect to the Biosecurity Act because we are looking at 2032, however if you look at the language itself. When that whether their grandfather periods or not what things are exempt, those are still unclear and so while that is sort of baking, this is the time to get your house in order. Insurers also need to consider the fact, at least is from a US perspective, certain knowledge of types of activities that are going on that are illicit can give rise to civil, criminal and of course reputational risk and so that can be a forced labour context. It is not necessarily under UFLPA or another statute called the Trafficking and Victims Prevention Act or TVPA and we know from our Government sources that this is being stated for increased enforcement as an additional US tool to spur China de-risking or de-coupling.

Sharmela: I was going to say to our audience if you have any questions let us know. I definitely have two more that I'd like to ask the panel. What opportunities do you think this creates for perhaps trading collaboration with other countries?

Evan: I think from US perspective we are now, we have moved from offshoring to something called friendshoring where we are essentially trying to find a relationship with our friends. I have actually been in meetings including former Government officials of those jurisdictions that we deem in the US to be sort of "friends" so in countries like Mexico, Japan, Korea, Vietnam. I think all of those countries and their pharma CDMO type of industries stand to benefit from China de-risking. There has definitely been a huge reliance on China for many years and so there is a legal and technical and really business piece that kind has to be checked out. But I think that there are also, it could be coincidental, but there are also national local issues in some of these jurisdictions, where the local governments also want to stand up for very strong pharma life science sector and so you may have a number of forces that are converging together. But that might present opportunities for both the EU and US pharma and life sciences companies.

Sharmela: Bernardine, good to get your thought here.

Bernardine: Yeah, absolutely. But by the same token some of these countries are going to be challenged to step up to be sufficiently sophisticated, to be enticing for that level of trade. A example, in particular it needs to up the game in terms of IP protections so that possibility is there, the opportunity is there but it is for those states to rise to the challenge to present a real alternative.

Evan: India's a good example right, in terms of it has technology, it has the manpower at least for some of the analyses I've seen, people are concerned about the state of its IP protection as well as the sort of political environment there. That is another big friend there but special concerns, I think.

Sharmela: Yes, and the final question really is, if I was a Chinese company listed in the Act or yet to be identified, what kind of measures should I be considering? It's a tough one.

Evan: Yeah, it is. I would say in my own experience, Chinese companies are highly pressured these days. I think at least in my meetings with both counsel as well as the company's principles themselves, I think many of them are feeling the pressure that certainly the US measures are taking and probably global measures are taking on them. I think that they are going to need to really understand and I think they are already doing it, they are trying to replace but they are coming up with something else in sort of a non-US non-EU and that is sort of the obvious path. But I think the thing that they tend to move towards, that we have seen and that I think that US and EU companies need to be very careful about, is really the notion that some of those plans include potentially obscuring supply chains. They include, I mean just as we need them, as a practical matter because they have been such a dominant player in certain processes, I think they need us, and particularly in the US extra markets, and so kind of splitting that up is very hard to do. There are sort of things that are being proposed and certainly have caught the eye of our US congress, particularly, we have a select committee on the strategic competition between the United States and the Chinese Communist Party. They pointed at things that Chinese companies had put in their disclosure statements as a matter of public securities filings. That are really are potentially trouble. I guess to a Chinese company, you want to be very careful about what you are disclosing and why and 2) you want to as a US company be very vigilant about who your suppliers and what they are saying. They are really having the resource to come through Chinese public securities filings if you are dealing with a Chinese publicly listed company. I think also there are Chinese companies that are trading companies. So, for some of these things, they are not the actual maker of certain items or inputs, they procure from somewhere else. From our experience, it is very difficult to get clarity where those things are really coming from and whether it causes some possible company of concern issue, whether it is a biotech or forced labour. So those are the things we certainly advise our clients to stay very, very vigilante in these sort of increasingly complicated compliance environments.

Sharmela: Thank you for that. Thats great, a good insight. Bernardine, I don't know if you have anything to add to that.

Bernardine: Yeah. Something I find of interest is the CPTPP, which I'm very proud to be able to say that, the trans-pacific agreement, which it's so ironic because the US really put that together almost as a bit to build an anti-China bloc in the pacific to create a strong economic trading bloc vis a vis China; Trump pulls out, US pulls out of it having put it together, and we won't go in to the fact that Britain for some bizarre reasons wanted to join it, but China now has applied for accession. So clearly where China will actually now sort of focus more on pacific, it is losing the Anglo-Saxon European market, so that it clearly will move towards the pacific. But Evan also said, I think people need to be careful around circumvention. So when Chinese actors start masking what they are by investing elsewhere in Malaysia and the packaging is something that originates from Malaysia but actually it has come by the back door from China and people need to be very, very wary of that and I dare say we will get US and the EU will follow and we'll get anti-circumvention regulations in place.

Sharmela: Yeah. Well thank you both. I feel like its really understanding the supply chain, understanding where the risks are and really keeping an eye on the developments from a legislative point of view from a regulatory point of view and also a US administrative point of view and EU .So we are at the end of our webinar. Thank you both for your helpful insights. We now have a better understanding of the Biosecure Act. If anybody has any other questions, please do follow up with the panellist directly and thank you for joining us and enjoy the rest of your day wherever you are.